PD-0476-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 5/26/2015 5:27:42 PM
Accepted 5/28/2015 2:35:42 PM
No. PD-0476-15 ^^cl^rk
In the
Court of Criminal Appeals
At Austin
♦ •
No. 01-13-00990-CR ,Q A^
In the "
Court of Appeals , ^ >^
for the
First District of Texas
PC
at Houston
No. 1315239
In the 176th District Court
Harris County, Texas
JOSE FRANCO CAMPUZANO
Appellant
V.
THE STATE OF TEXAS
Appellee
APPELLANT'S SECOND MOTION FOR EXTENSION OF TIME
WITHIN WHICH TO FILE
PETITION FOR DISCRETIONARY REVIEW
FILED IN
COURT OF CRIMINAL APPEALS
May 28, 2015
ABELACOSTA, CLERK
l/
TO THE HONORABLE COURT OF APPEALS:
APPELLANT, pursuant to TEX. R. App. P. 68.2(c) moves for an extension of
time within which to file its petition for discretionary review. In support of its
motion, appellant submits the following:
1. Appellant was charged with the felony offense of intoxication
manslaughter.
2. A jury convicted appellant of the charged offenses and sentenced him to
15 years confinement in the Institutional Division of the Texas
Department of Criminal Justice on October 15, 2013.
3. A unanimous panel of the First Court of Appeals rendered judgment in
an unpublished opinion on March 26, 2015, affirming appellant's
conviction and sentence.
4. After one extension was granted, appellant's petition for discretionary
review is due on May 26, 2015.
5. Appellant seeks a short extension, in accordance with TEX. R. APP. P.
68.2(c), until June 2, 2015, to file its petition for discretionary review.
6. The following facts are relied upon to show good cause for the
requested extension:
a. Counsel has been delayed in completing the petition due to the
recent flooding in the Houston area on May 24, 2015. High water
resulted in school closures, as well as counsel's inability to travel into
the city to her office to complete the petition.
b. Appellant's petition is not for purposes of delay, but so that justice may
be done.
WHEREFORE, the Appellant prays that this Court will grant the requested
extension until June 2, 2015.
Respectfully submitted,
/s/Mandy Miller
Attorney for appellant
2910 Commercial Center Blvd., Ste. 103-201
Katy, TX 77494
SBN 24055561
PHONE (832) 900-9884
FAX (877) 904-6846
mandy@mandymillerlegal.com
CERTIFICATE OF SERVICE
Pursuant to TEX. R. APP. P. 9.5, this certifies that on May 25, 2015, a copy of
the foregoing was delivered to the following addresses:
Melissa Hervey
Harris County District Attorney's Office
hervey melissa@dao.hctx.net
Lisa McMinn
State Prosecuting Attorney
lisa.mcminn@spa.state.tx.us
/s/Mandy Miller
Campuzano, Jose Franco
Combined Opinion